BROWN v. COMMISSIONER

Docket No. 4191-68.

30 T.C.M. 708 (1971)

T.C. Memo. 1971-166

Robert S. Brown and Sara M. Brown v. Commissioner.

United States Tax Court.

Filed July 19, 1971.


Attorney(s) appearing for the Case

Mark B. Edwards, 900 North Carolina Natl. Bank Bldg., Charlotte, N. C., for the petitioners. James D. Burroughs, for the respondent.


Memorandum Findings of Fact and Opinion

IRWIN, Judge:

The Commissioner determined a deficiency in petitioners' income tax for the taxable year 1961 in the amount of $71,531.09. The sole issue for decision is whether petitioners received ordinary income in the amount of $112,214.451 upon the transfer to them of certain real property by The Clinton Corporation.

Findings of Fact

Some of the facts have been stipulated...

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